Japan


Promotion of employment of persons with disabilities

Impact date: 1 July 2026

The statutory employment rate for people with disabilities has increased to 2.7%, and employers with 37.5 or more employees are now generally required to employ at least one person with a disability.

Employers meeting the above threshold are required to report their employment status regarding people with disabilities to the Employment Support Agency as of 1 June of each year.

Employer implications/action needed Employers should take steps to comply with the amended law.

Employer risk Failure to comply with the new regulations may result in the employer being required to develop a plan to hire people with disabilities, and failure to comply with such a requirement may result in public disclosure of the employer’s non-compliance.

Link N/A

Industrial Safety and Health Act

Impact date: 1 October 2026 Employers will be obliged to take measures necessary to protect their employees from actions by the employer’s clients that harm the employees’ working environment (such as extreme complaints, violence against employees or any other actions defined as “harassment by customers”).

Employer implications/action needed Employers should take steps to comply with the amended law.

Employer risk Failure to comply with the new regulations may result in informal counsel, administrative guidance, or a formal corrective recommendation, and failure to comply with such a recommendation may result in public disclosure of the employer’s non-compliance.

Link N/A

Part-time employees and fixed-term employees

Impact date: 1 October 2026

When hiring part-time or fixed-term employees, in addition to the current required disclosures (pay raises, retirement allowance, bonuses, help desk) regarding working conditions, it will be necessary to include a new disclosure stating that employees may request an explanation regarding the details and reasons for any differences between their treatment and the treatment of regular employees.

Employer implications/action needed Employers should take steps to comply with the amended law.

Employer risk Failure to comply with the new regulations may result in a fine of up to 100,000 yen.

Link N/A

Guidelines on Equal Pay for Equal Work

Impact date: 1 October 2026

The Guidelines on Equal Pay for Equal Work will be revised on 1 October 2026 to provide additional guidance on how to determine whether differences in treatment between regular and part-time employees are unreasonable, including specific examples such as accident-free bonuses, family allowances, housing allowances, fees for using employee welfare facilities, sick leave, and summer vacation.

Employer implications/action needed Based on the additional guidance, employers should consider whether any changes need to be made to their internal working conditions.

Employer risk Failure to comply with the concept of Equal Pay for Equal Work may give rise to a risk of a claim for damages under the Civil Code.

Link Guidelines

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Contacts

Kengo Ishikawa Partner


E: k-ishikawa@tmlo.jp T: +813 3214 2491

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Mayu Yada Associate


E: m-yada@tmlo.jp T: +813 3214 2491

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